DISCLAIMER: This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A, for use in discussions with the National Institute for Occupational Safety 

and Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its Working 

Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, draft or working 

documents are not final NIOSH or ABRWH products or positions, unless specifically marked as such. This 

document prepared by SC&A represents its preliminary evaluation on technical issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

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MEMORANDUM

TO: Advisory Board on Radiation and Worker Health Work Group on TBD-6000 

FROM: Robert Anigstein and John Mauro, SC&A, Inc.

DATE: September 6, 2016 

SUBJECT: Review of Appendix BB, Revision 2 

Review of “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals 

Appendix BB – General Steel Industries,” Revision 2

On May 26, 2016, David Allen (NIOSH/DCAS) issued Revision 2 of Appendix BB to 

TBD-6000 (Allen 2016). In an email message on June 13, 2016, Ted Katz, Designated Federal 

Official to the Advisory Board on Radiation and Worker Health (ABRWH), asked SC&A to 

review this report. 

Revision 1 of Appendix BB to TBD-6000 was issued on June 23, 2014 (Allen 2014). On 

December 10, 2014, Anigstein and Mauro (2014) issued a review of this document that included 

nine findings. On January 26, 2015, Anigstein and Mauro (2015a) issued a review of the first 

NIOSH response paper (Allen 2015a). In the process of preparing our replies, we found another 

issue, which became Finding 10. In a series of reports spanning the period January 8, 2015–

July 10, 2015, NIOSH responded to the SC&A findings. The NIOSH responses and our replies 

to the NIOSH reports were discussed at meetings of the Work Group on TBD-6000 held by 

teleconference on February 5, 2015, and November 3, 2015. In the course of the reports and 

memos issued by NIOSH and SC&A, and the discussions during the work group meetings, 

NIOSH and SC&A reached agreement on resolving all 10 findings. The work group concurred 

with the resolution of these findings.

1 Resolution of SC&A Findings on Appendix BB, Revision 1 

The first step in the present review is to verify that Allen (2016) correctly implemented the 

agreed-upon resolutions of the 10 findings on Appendix BB, Revision 1, which are discussed 

below in numerical order. We first state the original finding, and then follow it with a discussion 

of the NIOSH response to the finding and its final resolution in the revised appendix. 

1.1 Finding 1: Neutron Dose Rates 

Allen (2014) cited values of neutron dose rates without specifying which dosimetric quantities 

were calculated. Based on the similarity of his numerical values to neutron effective doses 

calculated by SC&A for the same scenarios, we concluded that Allen’s values represented 

effective dose rates, which are incompatible with the dose conversion factors (DCFs) listed in 

OCAS-IG-001 (OCAS 2007). To resolve this finding, Allen (2015a) stated that “DCAS will 
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revise the calculations to use either ambient dose equivalent or deep dose equivalent 

conversions.” 

In reviewing the revised appendix, we find that Allen (2016) lists revised values of neutron 

doses, but does not identify the dosimetric quantity. Such information is needed by dose 

reconstructors for selecting the appropriate DCFs in OCAS-IG-001. Based on the similarity of 

the numerical values listed by Allen to neutron ambient dose equivalent, H*(10), rates calculated 

by SC&A for the same scenarios, we conclude that these doses are stated in terms of H*(10). 

Allen (2016) states that the neutron doses derived from MCNPX simulations should be assumed 

to originate from neutrons with energies of 100 keV to 2 MeV in calculating organ doses. To see 

if this assumption was claimant favorable, we chose the lung as a representative organ and 

calculated the neutron dose rates to the lungs of the betatron operator and of the layout man. We 

first followed the method prescribed by NIOSH, multiplying the total neutron H*(10) rate at 

each location by the H*(10)-to-organ-dose-equivalent (HT) conversion factor for 100 keV to 

2 MeV neutrons listed in OCAS-IG-001. We compared these results to the neutron doses to the 

lungs determined by multiplying the H*(10) rates in each of the energy intervals listed in OCASIG-001 at each location by the corresponding DCF and summing the results. The results are 

shown in Table 1. 

Table 1. Comparison of Neutron Dose Rates to Lungs Calculated by Two Methods 

(mrem/shift)

Energy

range

Lung 

DCF

Betatron operator Layout man

Uranium

radiography

Uranium

handling Uranium total Steel radiography Steel radiography

H*(10) H*(10) H*(10) Lung H*(10) Lung H*(10) Lung

0–10 keV 1.523 0.574 0.003 0.577 0.879 0.160 0.244 0.106 0.162

10–100 keV 0.751 0.100 0.047 0.147 0.111 0.058 0.044 0.084 0.063

0.1–2 MeV 0.579 0.731 0.795 1.526 0.884 0.588 0.340 1.413 0.818

2–20 MeV 1.004 0.063 0.006 0.069 0.069 0.051 0.051 0.234 0.235

Total — 1.469 0.851 2.319 1.942 0.857 0.679 1.837 1.278

NIOSHa 0.579 1.469 0.851 2.319 1.343 0.857 0.496 1.837 1.064

Δ

b — — — — 45% — 37% — 20%

a Lung dose calculated using lung DCF for 0.1-2 MeV neutrons b Δ = Total ÷ NIOSH − 1

The table shows that using the more exact method results in a 45% higher neutron dose to the 

lungs of the betatron operator during the betatron radiography of uranium and the subsequent 

handling of uranium metal, a 37% higher dose during the radiography of steel, and a 20% higher 

neutron dose to the lungs of the layout man. We recommend that NIOSH assigns doses based on 

the actual neutron energies, which is more claimant favorable and scientifically accurate, and 

consistent with OCAS-IG-001, which is itself a simplification of ICRP publication 74 (ICRP 

1996). 
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1.2 Finding 2: Beta Skin Dose

Allen (2014, Table 5) listed annual beta doses to the skin of the betatron operator, other than the 

skin of the hands and forearms, that were 12%–33% lower than the values calculated by SC&A. 

The beta doses to the skin of the hands and forearms were 3%–14% lower than our values for the 

years 1963–1966. In a paper responding to Anigstein and Mauro (2014), Allen (2015c) listed 

revised beta doses to the skin of the betatron operator. In our review of Allen’s response paper, 

we listed our recalculated doses from handling uranium metal and noted that Allen’s doses were 

higher. In Appendix BB, Revision 2, Allen (2016, p. 17) cites doses to the skin of the whole 

body and of the hands and forearms of the betatron operator as 32.4 and 506 mrad per shift, 

respectively. These are identical to doses calculated by SC&A. Allen discusses the general 

methodology used to derive doses to the skin from exposure to freshly irradiated steel, but does 

not present detailed results of these calculations. Allen (2016, Table 5) lists the annual doses to 

the skin of the betatron operator during the covered period. We note that these are consistently 

higher than the SC&A values, the differences ranging from 0.2% to 3.4%. The differences 

increase with increased annual work shifts spent on radiographing steel, which indicates that the 

differences in the skin doses are due to differences in calculating the doses from steel, given the 

agreement on skin doses from uranium metal. As will be shown later in this review, the betatron 

operator represents the limiting exposure scenario for doses to the skin of the hands and forearms 

during 1952–1966, and to the skin of the rest of the body during 1952–1962. Allen’s skin doses 

from these exposure scenarios are within 2.5% of the SC&A values. Since these differences are 

small and claimant favorable, the NIOSH values are acceptable for use in dose reconstructions. 

We thus conclude that NIOSH has resolved Finding 2. 

1.3 Finding 3: No Dedicated Radiographic Facility in No. 6 Building Prior to 1955 

The GSI copetitioner presented credible evidence that the dedicated radiographic facility in No. 6 

Building was constructed in 1955. The mode of the triangular distribution of photon exposure 

rates during 1952–1962 listed by Allen (2014, Table 8) is based on the use of that facility. 

Assuming that the radiographer remained at the 2 mR/h boundary of the controlled area during 

the radiographic exposure rather than in the radiographer’s office, SC&A calculated the mode to 

be 11.28 R/y during 1952–1955. In a response paper, Allen (2015a) recalculated the annual 

exposure to be 11.34 R/y, using a slightly longer exposure duration at the boundary of the 

controlled area, which is consistent with the exposure scenario based on use of the radiographic 

facility. Allen (2016, Table 8) lists the mode of the triangular distribution to be 11.345 R/y for 

1952–1955. NIOSH has thus resolved Finding 3. 

1.4 Finding 4: Maximum of Triangular Distribution of Photon Exposures for 1961 

Should Be 12 R/y

Because AEC lowered the exposure limit to a maximum of 3 R per quarter, or 12 R/y, effective 

January 1, 1961, the maximum of the triangular distribution of photon exposures for 1961 should 

be 12 instead of 15 R/y (Allen 2014, Table 8). Allen (2016, Table 8) lists the maximum of the 

triangular distribution to be 12 R/y for 1961–1962. NIOSH has thus resolved Finding 4. 
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1.5 Finding 5: Combined Exposures to 226Ra and Betatron Operations During 1952–

1962 

Since radiography using 226Ra sources only occurred during 30% of a given shift, it is plausible 

that the same radiographer could be working in the betatron, performing radiography on uranium 

and steel, during the remainder of his shift. It is plausible and claimant-favorable to assume that 

the radiographer would participate in all the uranium work during a given year and would spend 

the balance of his time on the betatron radiography of steel. He should thus be assigned a beta 

dose to the skin as well as a neutron dose in addition to a triangular distribution of photon 

exposures during 1952–1962. 

In the first NIOSH response, Allen (2015a) argued that radiography using 226Ra took up an entire 

shift. However, during a meeting of the Work Group on TBD-6000, held by teleconference on 

February 5, 2015, three of the four work group members agreed with or leaned towards the 

SC&A position. In a subsequent response, Allen (2015c) proposed adding 38.75% of the values 

listed by Allen (2014, Table 1) to the radium radiography dose. During a meeting by 

teleconference on November 3, 2015, the Work Group on TBD-6000 recommended that the 

radiographer using radium be assumed to have spent 50% of his shift in the betatron building, 

and that he likewise be assumed to have performed 50% of the uranium radiography in any given 

year. NIOSH and SC&A concurred with these recommendations. 

Allen (2016, Table 8) shows that the annual exposure of the operator for organs other than the 

skin of the hands and forearms during 1952–1962 consists of the triangular distribution from 

226Ra radiography plus one-half of the air kerma from the residual betatron radiation. Also 

included is one-half of the beta dose to the skin of the whole body and one-half of the total 

neutron dose for each year that are listed in Table 5. The combined doses listed in Table 8 

comply with the work group’s recommendation for this scenario for the time period in question. 

However, as discussed under Finding 1, above, separate neutron doses should be specified for 

each energy interval.

1.6 Finding 6: Beta Skin Dose to Layout Man 

The beta doses to the skin of the layout man listed by Allen (2014, Table 6) were significantly 

lower than those that had been calculated by SC&A. In response, Allen (2015b) developed a new 

model of the exposure of the layout man to irradiated steel, taking into account the intermittent 

nature of the betatron radiographic exposures. In our reply to Allen’s proposed model, Anigstein 

and Mauro (2015b) agreed that the scenarios, although not realistically describing the operations 

at GSI, were physically possible and appeared to be conceptually bounding. We disagreed with 

the assumption that it would take the same amount of time to mark the defects on a thin casting 

as on a thick one. We proposed a ratio of 3:1, which resulted in 25% of the layout man's time 

being spent on long shots, and listed the beta doses resulting from this modified scenario. During 

a meeting of the Work Group on TBD-6000, held by teleconference on November 3, 2015, 

NIOSH agreed to adopt the assumption that the layout man spent 25% of his time on long shots. 

The work group unanimously concurred that NIOSH had agreed to resolve the issue reflected in 

Finding 6 and that this finding can therefore be closed. The beta doses to the skin of the layout 

man listed by Allen (2016, Tables 8 and 9) are about 1% higher than our calculated values 

(Anigstein and Mauro 2015b, Table 4), the differences being attributable to differences in 
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calculating the betatron beam intensity. These differences are small and claimant favorable; 

NIOSH has thus resolved Finding 6. 

1.7 Finding 7: Uranium Inhalation From Metal Handling in 1966 

Due to an apparent calculational error, the inhalation of uranium dust during the handling of the 

metal during the first 6 months of 1966 was understated by a factor of 2. The corrected value is 

listed by Allen (2016, Table 10). NIOSH has thus resolved Finding 7. 

1.8 Finding 8: Ingestion Intakes Not Consistent with OCAS-TIB-009 

The intakes of uranium particulates via ingestion listed by Allen (2014, Table 10) were 

significantly higher than the rates derived by applying OCAS-TIB-009 (OCAS 2004) to the 

airborne uranium dust concentrations, averaged over the work year. Although Allen’s rates were 

claimant favorable, we believed that they should be corrected for the sake of consistency with 

other site profiles, or an explanation given why these rates are valid. Allen (2015a) responded 

that DCAS agreed that it would be more appropriate to use the average airborne activity for the 

year. However, DCAS suggested using the average annual airborne activity for the highest year 

rather than changing the ingestion rate based on the amount of uranium work for a particular 

year. During a meeting by teleconference on February 5, 2015, the Work Group on TBD-6000 

unanimously concurred that NIOSH had agreed to resolve the issue reflected in Finding 8 and 

that this finding can therefore be closed. The value of 2.38 dpm/day listed by Allen (2016, 

Table 10) complies with the agreed-upon resolution of this issue. NIOSH has thus resolved 

Finding 8. 

1.9 Finding 9: Ingestion Intakes During Residual Period

The intakes of uranium particulates via ingestion during the residual period listed by Allen 

(2014, Table 11) were inconsistent with OCAS-TIB-009 (OCAS 2004), as discussed in 

Finding 8. Furthermore, they were inconsistent with Allen’s methodology for the operational 

period, since the rate for the first year is the inhalation, rather than ingestion, rate during the last 

year of the period of AEC operations. Allen (2015a) responded that DCAS intends to use the 

ingestion rate for the highest operational year for the beginning of the residual period in the next 

revision to Appendix BB. Allen (2016, Table 11) lists 2.38 dpm/day as the ingestion rate for the 

period July 1, 1966–December 31, 1967, decreasing by ~21.7% per year in subsequent years, 

which is consistent with the recommendation in ORAUT-OTIB-0070, Rev. 01 (Sharfi 2012, 

Table 4-2). The date range for the initial ingestion rate spans 18 months and thus is slightly more 

conservative than the recommendation in ORAUT-OTIB-0070, which stated that the depletion 

adjustment factor for Year 1 of the residual period should be 1.00. However, it is consistent with 

the NIOSH procedure of assigning intakes by calendar year (except for the need to split the year 

1966 between the operational and residual periods). This procedure is claimant favorable and is 

not likely to have a significant impact on dose reconstructions. NIOSH has thus resolved 

Finding 9. 
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1.10 Finding 10: External Exposure of Betatron Operator 

Allen (2014, Table 9) listed estimates of doses to the skin of the hands and forearms of the 

betatron operator during 1952–1963 as 1,300 mrem/y. This value was based on the hypothetical 

30-keV residual photon radiation from the betatron apparatus after shutdown and was calculated 

in terms of effective dose rates, which are incompatible with the DCFs listed in OCAS-IG-001 

(OCAS 2007). 

We proposed an alternative method of deriving doses to the skin as well as to other organs from 

the residual photon radiation from the betatron apparatus (Anigstein and Mauro 2015a). Our 

estimate employed assumptions and methods similar to those used to derive our earlier estimate 

of 26 mrem/week effective dose (Anigstein and Olsher 2012). That dose was based on the ratio 

of absorbed dose to the female breast from 30-keV photons in the posteroanterior (PA) 

orientation to air kerma listed by ICRP (1997, Table A.5). Using this value—0.0489 Gy/Gy—we 

derived a value of 204.5 mrad/week air kerma that corresponds to the MDA of the film badge 

dosimeter of 10 mrem (10 mrem/week ÷ 0.0489 = 204.5 mrem/week). Since OCAS-IG-001 does 

list air-kerma-to-organ-dose conversion factors, this quantity can be used for dose 

reconstructions. Since the radiation is assumed to have an energy of 30 keV, we recommended 

that NIOSH uses the maximum DCF listed in OCAS-IG-001 for photons with energy 

(E) < 30 keV in the PA orientation.

Allen (2015c) accepted our proposed value of 204.5 mrad/week air kerma in the PA orientation. 

Allen proposed using this air kerma rate, together with the air-kerma-to-skin-dose conversion 

factor for photons, E < 30 keV, to calculate the dose to the skin on the back and sides. However, 

he assigned only one-half of this dose to the skin of the hands and forearms, since he assumed 

that the worker's hands were at the side of the body only one-half of the time and in front of the 

body the rest of the time. He assigned an additional dose of one-half the MDL of the film 

badge—5 mrem/week or 0.25 rem/y—to account for the time the hands were in front of the 

body. He assigned a dose of 0.5 rem/y to the skin on the anterior portion of the body, other than 

the skin of the hands and forearms . 

We agreed that the worker would not always have his hands at his sides; however, we did not 

agree that his hands and forearms would have been completely shielded by his torso during onehalf of the time he was working (Anigstein and Mauro 2015b). That would happen only if his 

hands and forearms were held close together, which cannot be assumed to occur during one-half 

of his activities. Although some shielding of the hands and forearms by the torso may have 

occurred during some unknown portion of the setup period, in the absence of more specific 

information, we recommended that NIOSH assign bounding doses to the skin of the hands and 

forearms of 6.687 rem/y (10.225 rad air kerma × 0.654 rem/rad = 6.687 rem). Ziemer (2015) 

reported these proposed values to the ABRWH and stated that the Work Group on TBD-6000 

voted to accept the SC&A assumption and that NIOSH had agreed. 

Allen (2016, Table 9) includes a “gamma dose” to the skin of the hands and forearms of the 

betatron operator of 10.225 rad/y, but does not identify it as air kerma. A footnote to the table 

identifies the energy as E < 30 keV in the PA geometry, but does not specify which DCF value 

should be used in dose reconstructions. The footnote should be revised to specify a DCF of 
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0.654 rem/rad, as cited above. Allen (2016, Table 8) likewise includes a contribution of 

5.112 rad/y to the “gamma dose” to all organs except the skin of the hands and forearms during 

1952–1962. This is based on the agreed-upon scenario of the radiographer’s dividing his time 

equally between betatron operations and radiography using 226Ra. Footnotes to Tables 8 and 9 

identify the photons as having E < 30 keV in the PA geometry, but do not specify which DCF 

value should be used in dose reconstructions. Since the residual radiation from the betatron is 

hypothesized to have an energy of 30 keV, the maximum rather than the average DCF that 

corresponds to E < 30 keV should be used for dose reconstructions. These footnotes need to be 

revised before NIOSH can be deemed to have resolved Finding 10. 

2 Limiting Exposure Scenarios

Because of the changes in doses to both the betatron operator and the layout man from the 

previous version of the appendix for the years 1963–1966, we need to review the selection of the 

limiting exposure scenario for each of these years. 

In the first paragraph under the subheading “Operators,” Allen (2016) states: “After 1962, the 

bounding estimate is the layout man dose estimate for most cases. In the case of the skin to of the 

hands or forearms, the betatron operator dose estimate is limiting.” A minor wording error is 

shown by the crossed out word in blue and the inserted word in red. More important, this 

statement is inconsistent with Allen’s Table 9, which lists the betatron operator as the limiting 

exposure scenario for doses to the hands and forearms in 1963, but the layout man for 1964–

1966. To resolve this ambiguity and to confirm the assignment of limiting doses to the skin of 

the hands and forearms, and to the skin of the rest of the body, we calculated the doses to the 

skin of a worker in each of these two positions during the years 1963–1966. 

Table 2. Annual Doses to Skin of Betatron Operatora

Year Neutron: 

H*(10)

DCF: neutron 

H*(10)b

Neutron 

dose

Air kerma 

(mrads)

DCF: air 

kermac

Photon 

dose

Beta dose 

(WB)d

Skin dose 

(WB)d

Beta dose 

(H&F)e

Skin dose 

(H&F)e

1963 365 0.879 321 10,225 0.654 6,687 1,530 8,538 6,630 13,638

1964 356 0.879 313 10,225 0.654 6,687 1,350 8,350 3,590 10,590

1965 354 0.879 311 10,225 0.654 6,687 1,320 8,318 3,110 10,108

1966f 176 0.879 155 5,112 0.654 3,344 650 4,148 1,320 4,818

a All doses are in units of mrem unless otherwise noted.

b DCF for neutrons 0.1 MeV ≤ E ≤ 2.0 MeV

c See discussion in section 1.10 of the present review

d Skin of the whole body (excluding hands and forearms)

e Skin of the hands and forearms

f Six months of operations

Table 2 lists the annual doses to the skin of the betatron operator from neutrons, photons, and 

beta rays for each year from 1963 to 1966. We first list the estimated external dose rate from 

each type of radiation, followed by the appropriate DCF taken from OCAS-IG-001, followed by 

the product of the DCF and the dose rate, which is the annual skin dose from the radiation in 

question. (No DCF is listed for beta dose, since the factor is implicitly equal to unity.) The 

columns headed “Skin dose (WB)” and “Skin dose (H&F)” list the total dose—the sum of the 

contributions from each type of radiation—to the skin on the indicated portion of the body. 
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Table 3. Annual Doses to Skin of Layout Man (1963–1966)a

Year Neutron:

H*(10)

DCF: neutron 

H*(10)b

Neutron 

dose

Exposure 

(mR)

DCF: 

exposurec

Photon 

dose

Beta dose 

(WB)d

Skin dose 

(WB)d

Beta dose 

(H&F)e

Skin dose 

(H&F)e

Allf 751 0.879 660 9,002 0.892 8,030 226 8,916 408 9,098

a All doses are in units of mrem unless otherwise noted.

b DCF for neutrons 0.1 MeV ≤ E ≤ 2.0 MeV

c DCF for photons 30 keV ≤ E ≤ 250 keV

d Skin of the whole body (excluding hands and forearms)

e Skin of the hands and forearms

f Years 1963–1966; 6 months of operations in 1966.

Table 3 lists the same quantities for the layout man for the years 1963–1966. As shown in 

Tables 2 and 3, the layout man constitutes the limiting scenario for the dose to the skin, other 

than the skin of the hands and forearms, during the years 1963–1966. Since the beta dose makes 

little or no contribution to organs other than skin, the layout man also constitutes the limiting 

scenario for doses to other organs. Although the neutron doses to both the betatron operator and 

the layout man will increase if the doses are calculated separately for each energy range, as 

recommended in section 1.1 of the present review, such changes are not likely to alter this 

conclusion. As shown in these tables, the betatron operator constitutes the limiting scenario for 

doses to the skin of the hands and forearms for each year 1963–1966. This is consistent with 

Allen’s (2016) statement in the text of section BB.4.7, but not with Table 9, which lists the 

layout man as the limiting exposure scenario during 1964–1966. The last three rows of Table 9 

should be revised to list doses to the skin of the hands and forearms of the betatron operator 

instead of the layout man as the limiting exposure scenario during 1964–1966. 

3 Observations 

In our review of Appendix BB, Revision 1 (Allen 2014), Anigstein and Mauro (2014) made a 

number of comments intended to correct or clarify statements in the text which, although they 

did not affect the prescribed methods of dose reconstruction, did not accurately represent the GSI 

site or its activities. The comments also identified errors in wording in order to improve the next 

revision of Appendix BB. During a meeting of the Work Group on TBD-6000, held by 

teleconference on February 5, 2015, James Neton (NIOSH/DCAS) stated that editorial 

comments in the SC&A review of Appendix BB, Revision 1, would be addressed in Revision 2. 

In our present review, we found instances where revisions or clarifications would lead to a more 

accurate and defensible presentation of the site profile; we also found errors in wording in the 

revised text. These are discussed in the same sequence of as they were presented by Allen 

(2016). Unless otherwise specified, the section numbers are from Allen 2016. 
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3.1 Section BB.2.2: Frequency of Uranium X-Rays 

In Section BB.2.2, Allen (2014) describes the Mallinckrodt purchase orders covering the period 

March 1, 1958–June 30, 1966, as stipulating estimates or limits on monthly expenditures for the 

radiography of uranium metal shapes. Allen is correct in citing annual limits on expenditures in 

the purchase orders spanning the period July 1, 1961–June 30, 1966. We agree with the use of 

Mallinckrodt’s estimated expenditures to derive the hours of uranium exposure during the 

March 1, 1958–June 30, 1961, period. However, we recommend that for the period October 1, 

1952–June 30, 1961, NIOSH should refer to the uranium work hours derived from these 

estimates as “best estimates,” rather than “maximum” hours, so as not to overstate the degree of 

conservatism in the exposure assessments for that period. 

3.2 Section BB.4.1: Betatrons 

The description of the shooting room in section BB.4.1 described it as surrounded by 10-ft thick 

walls consisting of 8 ft of sand sandwiched between two 1-ft-thick concrete walls. However, 

Allen (2016, Figure 3) indicates 10 ft of sand between the shooting room and the control room, 

and 9 ft on the other three sides. These dimensions, as well as the 1-ft-thick concrete walls 

containing the sand, were incorporated in the MCNPX model of the New Betatron Building. The 

text should be revised to reflect these dimensions. 

Expanding on a comment by the copetitioner, we recommend that references to the “old 

betatron” and the “new betatron” in the second paragraph of section BB.4.1 be changed to “Old 

Betatron Building” and “New Betatron Building.” The construction dates cited by Allen (2016) 

refer to when the two buildings were erected. The text could be misinterpreted as referring to 

when the machines were manufactured.1

 Similar references to the construction of the New 

Betatron Building should include the word “building” to distinguish it from the betatron 

apparatus itself.

1

 The “New” betatron went into operation at the General Steel foundry in Eddystone, Pennsylvania, in November 1951 

and was later moved to the Granite City facility, while the “Old” betatron became operational at the Granite City foundry 

in January 1952. 

3.3 Section BB.4.3: Betatron Operations External Dose Estimate 

In section BB.4.3, Allen (2016) stated: “While shooting steel, the betatron was assumed to 

always be shooting a large steel object on a railcar. This angle produced the highest dose rate for 

the layout man location... [italics added]” “This angle” is not identified—the revised appendix 

should state that the beam was oriented in a horizontal direction, perpendicular to the casting. 

In discussions of the beta skin dose, Allen (2016) refers to dose rates at a distance of 1 cm from 

the surface of the metal and states that this was essentially in contact. In fact, the beta dose rates 

were calculated in actual contact with the surface of uranium and of irradiated steel—this should 

be corrected in the revised appendix. 

The sixth line of the second-to-last paragraph on p. 19 should be corrected by inserting the text 

shown in red: “only one casting is worked per shift.” 
Update of Doses from External Exposure at GSI 10 SC&A – September 6, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

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3.4 Section BB.4.4: External Dose Estimate for Isotope Source Operations 

In describing the triangular distribution of exposures from radium radiography, Allen (2016, 

p. 25) states: “The maximum will be the AEC limit (15 rem/yr or 12 rem/yr depending on the 

year) (AEC 1960, NBS 1949).” The reference “AEC 1960” is to a 1957 issue of the Federal 

Register in which AEC prescribed a limit of 300 mR/week, the same as in NBS Handbook 41, 

cited by Allen as “NBS 1949.” The notice that lowered the maximum annual exposure to 12 R/y 

is found at “Federal Register 25(224), 10914–10924.” The Federal Register citation should be 

corrected in the list of references.

3.5 Section BB.4.7: External Dose Estimate Summary 

The sixth sentence in the first paragraph of section BB.4.7 reads: “If it is assumed at least 

10 minutes is necessary for setting up and removing the film and other tasks associated with 

radium radiography to would total 100 minutes per shift.” There appears to be some text missing 

after the word “to.” 

3.6 References

Allen (2016) listed five new references that did not appear in the previous version of this 

Appendix (Allen 2014). We have already commented on the reference “AEC 1960” in section 

3.4 of the present review. Corrections are needed to three other references, as discussed below.

3.6.1 AEC 1963 

The reference “AEC 1963” refers to “Amendment 5,” and lists a date of February 14, 1968. The 

document which contains the cited information is Amendment 1, dated April 22, 1963. 

3.6.2 AEC 1968 

The reference “AEC 1968” lists a date of February 15, 1963. The correct date is February 14, 

1968.

3.6.3 MCNPX

The reference “MCNPX,” which is to the MCNPX user’s manual, version 2.7.0, has an incorrect 

document number and date. The document number is LA-CP-11-00438; it was issued in 2011. 

4 Conclusions

NIOSH has resolved Findings 2–9. Finding 1 remains unresolved until NIOSH addresses the use 

of energy-dependent DCFs to calculate neutron doses. Finding 10 would be resolved if NIOSH 

identifies the “gamma doses” listed by Allen (2016, Tables 8 and 9) as air kerma and specifies 

the use of the maximum DCFs for photons with E < 30 keV to convert these air kerma values to 

organ doses. Table 9 should be revised to indicate that the betatron operator constitutes the 

limiting exposure scenario for doses to the skin of the hands and forearms. 
Update of Doses from External Exposure at GSI 11 SC&A – September 6, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

References

Allen, D. 2014. “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals: 

Appendix BB – General Steel Industries,” Battelle-TBD-6000, Appendix BB, Revision No. 1. 

http://www.cdc.gov/niosh/ocas/pdfs/arch/b-6000-apbb-r1.pdf

Allen, D. 2015a. “Discussion of Remaining Issues to Sanford Cohen & Associates Review of 

Battelle-TBD-6000 Appendix BB (General Steel Industries, Rev. 1): Response Paper.” 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsiappbb-071015.pdf

Allen, D. 2015b. “General Steel Industries Layout Man Beta Skin Dose, Response Paper.” 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsilaybeta-010815.pdf

Allen, D. 2015c. “Discussion of Remaining Issues to Sanford Cohen & Associates Review of 

Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 1): Response Paper.” 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsiappbb-071015.pdf

Allen, D. 2016. “Site Profiles for Atomic Weapons Employers that Worked Uranium Metals: 

Appendix BB – General Steel Industries,” Battelle-TBD-6000, Appendix BB, Revision No. 2. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r2.pdf

Anigstein, R., and J. Mauro. 2014. “Update of Doses from External Exposure at General Steel 

Industries.” Memo to Advisory Board on Radiation and Worker Health Work Group on TBD6000. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiexdose-011214.pdf

Anigstein, R., and J. Mauro. 2015a. “Review of ‘Responses to Sanford Cohen & Associates 

Review of Battelle-TBD-6000 Appendix BB (General Steel Industries, Rev. 1), Response 

Paper’.” Memo to Advisory Board on Radiation and Worker Health, Work Group on TBD-6000 

(January 26, 2015). 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiapbbr1-012615.pdf

Anigstein, R., and J. Mauro. 2015b. “Review of ‘Responses to Sanford Cohen & Associates 

Review of Battelle-TBD-6000 Appendix BB (General Steel Industries, Rev. 1), Response 

Paper’.” Memo to Advisory Board on Radiation and Worker Health, Work Group on TBD-6000 

(September 11, 2015). 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsiapbbr1-091115.pdf

Anigstein, R., and R. H. Olsher. 2012. “Response to ‘Battelle-TBD-6000 Appendix BB General 

Steel Industries: Dose Estimates for Betatron Operations’.” 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsibeta-r0.pdf

International Commission on Radiological Protection (ICRP). 1996. “Conversion Coefficients 

for use in Radiological Protection against External Radiation,” ICRP Publication 74. Annals of 

the ICRP, 26 (3/4). Tarrytown, NY: Elsevier Science, Inc. 
Update of Doses from External Exposure at GSI 12 SC&A – September 6, 2016

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Office of Compensation Analysis and Support (OCAS). 2004. “Technical Information Bulletin: 

Ingestion Intakes,” OCAS-TIB-009, Revision No. 0. http://www.cdc.gov/niosh/ocas/pdfs/tibs/oct9-ro.pdf

Office of Compensation Analysis and Support (OCAS). 2007. “External Dose Reconstruction 

Implementation Guideline,” OCAS-IG-001, Revision No. 3. 

www.cdc.gov/niosh/ocas/pdfs/dr/oc-ig-001-r3.pdf

Sharfi, M. M. 2012. “Dose Reconstruction during Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities,” ORAUT-OTIB-0070, Rev. 01. 

http://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t70-r1.pdf

Ziemer, P. L. 2015. “Report of TBD-6000 Work Group Concerning Appendix BB Rev. 1 

Findings (General Steel Industries).” Presented at ABRWH Meeting 108, Oakland, California, 

November 18, 2015. http://www.cdc.gov/niosh/ocas/pdfs/abrwh/pres/2015/bd-tbd6000-

111815.pdfhttp://www.cdc.gov/niosh/ocas/pdfs/abrwh/pres/2015/bd-tbd6000-111815.pdf